Charlotte Brown

Expertise

My practice encompasses advisory and litigation work on all tax-related matters, both direct and indirect, with a particular emphasis on VAT and Customs Duty dispute resolution. I have appeared on behalf of clients in the Tax Tribunals and High Court, and assisted senior counsel with appeals through to the Higher Courts, including applications to the Court of Justice of the European Union. My clients have been both national and international, and include individuals, public bodies, small and medium enterprises and blue chip companies. Having previously worked within the tax litigation team of a solicitors’ firm and more recently within the indirect tax dispute resolution team of a Big 4 accountancy firm, I have significant experience in handling disputes with HMRC and in complying with the practice and procedure of the tax tribunals.

Examples of matters that I have been involved in include:

Taxation - Acting on behalf of taxpayers in relation to:

• Mitigating assessments, penalties and interest claims by HMRC;

• Procedural applications, such as applications for a hearing of preliminary issues to narrow the scope of the dispute, applications for a stay, applications for lead case status, applications for an extension of time, applications to reinstate an appeal and disclosure applications;

• A recruitment agency’s claim for overpaid VAT in relation to the supply of temporary workers;

• Claims for overpaid VAT in the gaming and leisure industry, medical services sector, financial services industry and on behalf of local authorities;

• Appeals relating to VAT single and multiple supply issues in the housing, leisure, retail and medical industries;

• MTIC fraud appeals in the mobile telephone, computer component and precious metal industries, involving millions of pounds of withheld input VAT;

• Appeals relating to VAT default surcharges, registration issues, hardship applications and notices of requirement for security;

• Judicial Review of HMRC’s decision to withhold input VAT and refusal to zero-rate ex works supplies made by an international client in the precious metals industry;

• Advising clients in relation to Customs classification, origin, valuation, preferences and reliefs across a broad spectrum of goods including medical equipment, electronic cigarettes, precious metals, automotive vehicles and construction machinery;

• Drafting Particulars of Claim for High Court claims of overpaid Landfill Tax paid under a mistake of law;

• Appeals against discovery assessments issued by HMRC in relation to IR20 and residence of the taxpayer;

• Advice on the income tax, national insurance and CGT implications of working abroad;

• Threatened winding up proceedings for Corporation Tax due. A settlement was reached and winding up proceedings withdrawn by liaising and negotiating with HMRC;

• Claims for compound interest;

• Advice on general estate planning and Inheritance Tax issues.

Commercial - Representing clients in relation to:

• The successful application and execution of freezing and search orders following an investment adviser’s breach of fiduciary duties;

• Ongoing litigation in relation to the enforcement of a guarantee. This required enforcement of judgments in the EU and Switzerland;

• The application and scope of the EU, UK and UN sanction regimes in relation to different jurisdictions for a multinational automotive client;

• An opinion for a bank debt claim involving letters of credit and guarantees that was placed before the court of Madrid.

Chancery - Acting on behalf of clients in relation to:

• Claims involving breach of trust, breach of fiduciary duties, removal of trustees and executors, and construction of wills and trust deeds;

• Advice on the beneficial entitlement of multiple properties where legal title was held solely and jointly;

• Challenging the validity of a will under the Inheritance (Provision for Family and Dependents) Act 1975.